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/21/16 ion Date

OPERATING PROCEDURE OP 14.1

Revision: R Page 2 of 20

QUALITY

Controlling Department

09/02/97

Issue Date

06/21/16

Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

1.0 PURPOSE: This procedure defines and controls the formal process for the Corrective/ Preventive action system at Breeze-Eastern (B-E). 2.0 SCOPE:

2.1 This procedure applies to the Corrective/Preventive Action System in support of regulatory, contractual, and third party requirements, and those actions necessary for Breeze-Eastern to achieve customer satisfaction by delivering cost effective, defect-free products and services.

2.2 This procedure is applicable to any reported non-conformance revealed during regulatory, customer, or internal audits, Inspection Reports (IR), customer complaints or other items requiring formal Corrective/Preventive Action. Warranty returns will be addressed separately and at the discretion of the Quality Representative performing the review and analysis. A CAR may be generated as a result of this effort.

2.3 This procedure outlines a process to eliminate the causes of non-conformance and to limit the potential for reoccurrence. Corrective actions taken conform to applicable regulations.

3.0 REFERENCES & DEFINITIONS:

3.1 Procedures

3.1.1 OP 16.1 Quality Records

3.1.2 OP 17.1 Compliance Evaluation Audits

3.1.3 OP 18.1 Training Program

3.1.4 OP 21.1 Special Requirements for FAA Regulated Parts

3.1.5 Q 10.003 Final Inspection Work Instruction

3.2 Forms

3.2.1 QC-1338 Corrective Preventive Action Request Form

3.2.2 QC-1398 Final Inspection Hold

3.2.3 BF-1064 Inspection & PMR Report

OPERATING PROCEDURE OP 14.1

Revision: R Page 3 of 20

QUALITY

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Issue Date

06/21/16

Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

3.2.4 QC-1421 Notification of Non-Conformance Requiring Action

3.3 Other Documents

3.3.1 N/A

3.4 Abbreviations and Definitions

3.4.1 AS – A Corrective Action identified as the result of an AS9100 Audit.

3.4.2 CUS - Customer Corrective Action Request

3.4.3 IA - Internal Audit Corrective Action Request

3.4.4 ICAR - Internal Corrective Action Request

3.4.5 ISO - Third Party Corrective Action Request when used in the CAR Log

3.4.6 VCAR - Vendor Corrective Action Request

3.4.7 HoQ - Head of the Quality organization

3.4.8 EMS - Environmental Management System

3.4.9 EMSSC - EMS Steering Committee

3.4.10 RSM - Repair Station Manual

3.4.11 CAA - Corrective Action Administrator: HoQ, or Quality Engineer, appointed by the HoQ, has the authority to close CAR(s) and conduct the daily operations of the Corrective/Preventive Action system.

3.4.12 CAB - Corrective Action Board: The CAB fulfills a management review function for the corrective/preventive action process.

3.4.13 CA/PA Corrective Action/Preventive Action: The action taken to eliminate the cause of the product, print, specification, contract, procedure or process non-conformance and to prevent future occurrences.

3.4.14 CAR - Corrective Action Request: The actual report of a non-conformance resulting in a corrective action request. Subsequent Containment or Immediate CA, Cause Analysis, Corrective/ Preventive Action and Action taken to determine if other products are affected are required for those non-conformances, required by the CAA or CAB.

OPERATING PROCEDURE OP 14.1

Revision: R Page 4 of 20

QUALITY

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Issue Date

06/21/16

Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

3.4.14.1 An electronic facsimile of a Corrective Action Request (CAR) response is acceptable providing the form integrity remains the same.

3.4.14.2 Refer to sample form in Appendix 2.

3.4.15 CAR Log - Corrective Action Request Log: Spreadsheet of Corrective/Preventive Actions. Master stored on Quality Dept. shared drive.

3.4.16 CAT - Corrective Action Team: - One or more persons assigned responsibility for the corrective action investigation and resolution of a specific problem or deficiency.

3.4.17 EO - Enhancement Opportunity: This form of action is associated with a Preventive Action. This type of notification is used prior to the detection of an actual non-conformance.

3.4.18 NC - Non-conformance Cost: Any cost incurred due to the failure to meet any agreed to requirement.

3.4.19 NOTIFY - A notification of a non-conformance that is to be addressed within a suppliers’ Corrective Action System, but does not require a written response to B-E.

3.4.20 PA/Preventive Action -The action taken to prevent the occurrence of a potential non-conformance prior to being identified as a non-conformance.

3.4.21 Root Cause - The definitive or true reason for a particular event that has taken place, which if corrected would prevent the creation of the non-conformance. The cause is usually identified as the Direct, Indirect or Contributing Cause with the Root Cause being the actual cause of the non-conformance. Root causes are often obscure and may require an in-depth root cause analysis to determine the actual root cause.

3.4.22 Timely Manner: An allotment of time solely established by the CAA or CAB determined as reasonable based on business needs, and which may be extended by the CAA, CAB, or at management’s option to accommodate changing business needs.

3.4.23 Containment Action – Containment action is the first step in this process. These are the actions taken immediately after becoming aware of the non-

OPERATING PROCEDURE OP 14.1

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Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

conformance to stop the non-conformance from occurring and preventing or minimizing any impact from the non-conformance or the immediate actions that prevent use or shipment of non-conforming product.

4.0 REGULATIONS AND RESPONSIBILITIES

4.1 Regulatory Requirements

4.1.1 14 CFR Part 21, Certification Procedures for Products and Parts

4.1.2 Advisory Circular AC 00-58 Voluntary Disclosure Program

4.1.3 AS9100C:2009 Quality Management Systems – Requirements for Aviation, Space and Defense Organizations.

4.2 Departmental Responsibilities

4.2.1 Quality Engineering and Supplier Quality members can assist with containment actions, supporting root cause determination, corrective action solutions, and review of effectiveness.

4.2.2 The Corrective Action Administrator (CAA) is the HoQ, or Quality Engineer appointed by the HoQ, and has the authority to close CAR(s) and conduct the daily operations of the Corrective/Preventive Action system.

4.2.3 Corrective Action Board (CAB): The CAB fulfills a management review function for the corrective/preventive action process.

4.2.3.1 The CAB is comprised of the departmental and functional management members, including Operations Management, Production Engineering, and Engineering, as applicable.

4.2.3.2 The Head of Quality (HoQ) is the CAB chairman.

4.2.4 The CAB has the responsibility and authority necessary to ensure the prevention of non-conformance(s), assess and manage non-conformance cost elimination, ensure that causes of non-conformance(s) are identified, and that corrective actions are implemented throughout the organization and the supply chain.

4.2.5 Corrective/Preventive Action System: As defined in this procedure, it applies to all manners of corrective and preventive actions as a result of

OPERATING PROCEDURE OP 14.1

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CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

audits, customer requests, or any document that contains a block for corrective action, and will be handled as specified.

4.2.5.1 The formal corrective action system consists of the CAB, the CAA and the CAT, as necessary.

4.2.5.2 A process flow chart is provided in Appendix 1.

4.2.6 The CAB functions and responsibilities include, but not necessarily limited, to:

4.2.6.1 Analyze non-conformances, including customer feedback and complaints to identify trends and initiate Corrective/Preventive Action efforts.

4.2.6.2 Determination of the root causes of non-conformances deemed a significant impact to the Company’s ability to meet its commitments.

4.2.6.3 Evaluating the need for action to ensure that non-conformities do not recur for those non-conformances determined to have a significant impact in the ability of the Company to meet its commitments.

4.2.6.4 Determining and implementing action(s) required to be taken.

4.2.6.5 Create and maintain records of the action taken by providing for receiving, recording and disseminating all manners of corrective action requests such as Customer Audit Findings, Audits, and Customer Requests for corrective action. .

4.2.6.6 Reviewing the effectiveness of the corrective action taken, defined by the responsible process owner or supplier, based on the significance of the non-conformance and its impact on the Company.

4.2.6.7 Flow down corrective action requirements to a supplier when it is determined that the supplier is responsible for the non-conformance.

4.2.6.8 Determining specific actions where timely and/or effective corrective actions are not achieved.

OPERATING PROCEDURE OP 14.1

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Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

4.2.6.9 Determining the containment actions if additional non-conforming product exists based on the causes of the non-conformities, taking further action when required.

4.2.6.10 Review the status of aged CA(s) to determine their significance or benefit to the continued use of resources and efforts to resolve, refocus resources to resolve them, or to close them.

4.2.6.11 Perform oversight reviews to ensure CA(s) are appropriate for the effects of the non-conformities, are timely, and are effective.

4.2.6.12 Respond to requests and directions from senior management regarding corrective action investigation and findings.

4.2.6.13 Convene the CAB a minimum of once yearly to ensure timely and effective actions are maintained.

4.2.6.14 Determine potential non-conformities and initiate preventive actions where required.

4.2.6.15 Establish priorities for CAT(s), when necessary.

5.0 PROCEDURE:

5.1 General Information 5.1.1 All CA/PA requests are to be considered an opportunity to improve. All

Containment, Corrective, and/ or Preventive actions taken are to be to the degree appropriate to the magnitude of the problem(s) and commensurate with risks, as determined by the CAA and / or the CAB.

5.1.1.1 For apparent regulatory violations uncovered as a result of internal investigations that fall under Title 14 of the Code of Federal Regulations, consideration should be given to voluntary disclosure as outlined in AC 00-58B, OP 21.1, or the RSM.

5.1.2 The CAA is provided customer requests for corrective action (CA), Vendor CA requests, Inspection Reports (IR), Customer Audit Findings, Internal Audit Findings and observations, CAR(s), findings identified by contract consultants performing an audit on behalf of the Company, and any additional requests for CA that are initiated.

OPERATING PROCEDURE OP 14.1

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CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

5.1.2.1 The CAA, or an acceptable designee, logs in CAR(s) to the B-E Corrective Action Request Log (CAR Log).

5.1.2.2 The CAR Log is located on the S: //Quality/CAR Log shared drive.

5.1.2.3 The CAA initiates the CAR, Form QC-1338, and completes the CAR Log entry by identifying the following:

• CAR CODE - type of CAR (IA, VCAR, CUS, etc.). • CAR # - CAR Number (next CAR number in sequence), • Department/Customer – department or customer name

initiating the request, initiator,

• The originator of the CAR,

• Responsible process owner or supplier - the responsible process owner or supplier,

• Date: - the date initiated,

• Due: - the date due,

• Customer CAR/IR Number (if applicable) of the source of the CAR information (e.g. IR#, QN#, SCAR#, PQDR#, etc.),

• Part Number, Nomenclature, P.O. Number and Quantity (as applicable) for the part, process, procedure or issue,

• Requirement Document: the reference to the document or reference which identifies the requirement for the product, print, specification, contract, procedure or process.

• Non-conformance to the requirement: The identification of the actual non-conformance identified to the requirements.

Note: The description of the non-conformance should be clear, concise and easily understood by the person receiving the CAR.

OPERATING PROCEDURE OP 14.1

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Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

5.1.2.4 The Word version of the CAR form gets saved in the associated CAR file located on the S: //Quality/CAR Log/CAR XXXX (year) directory using the CARXXXX (owner initials) format.

5.1.2.5 A PDF copy of the associated supporting documentation such as the originating IR gets stored in the same directory using the CARXXXIRXXXXX.pdf format.

5.1.2.6 A copy of the Word version of the CAR and the supporting documentation (IR, QN, QPDR, etc.) are to be sent to the responsible process owner or supplier via email. In the case of a VCAR, the email is to be sent to the buyer and the supplier where the email address is known by the CAA.

5.1.3 If a CAT involved in the CA process determines that the lack of resources is an issue, the CAT Leader is to contact the CAA for assistance. If the CAA cannot satisfactorily resolve the issue, the CAA will advise the CAB for a final resolution.

5.1.4 Any person within the Company has the right to and is encouraged to request the initiation of a CAR for any discrepancy that cannot be immediately resolved to their satisfaction or for repeated occurrences of the same non-conformance.

5.1.5 In many instances, quality problems are identified within a work area that is minor in nature and not interdepartmental or cross-functional. These quality problems do not require the generation of a CAR if resolvable by the workers or teams in the area. These corrective action efforts are outside of the formal process of this procedure and are accomplished on a direct interface basis. The person with the problem directly interacts and obtains immediate resolution. An example of this situation is the QC Form -1398, Final Inspection Hold, utilized in Q10.003 for Final Inspection.

5.1.6 CA(s) that are deemed to be vendor responsibility are to be flowed down to the vendor, as appropriate.

5.1.6.1 Supplier Non-conformances which are isolated in nature or do not rise to the level to warrant a written Corrective Action Request, may be entered into the CAR Log and identified as “NOTIFY” in the CODE. This form of CAR will be entered into the CAR Log

OPERATING PROCEDURE OP 14.1

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Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

and immediately closed and transferred to the closed CAR tab of the CAR Log. An effectiveness review or date is not required.

5.1.6.2 The associated documentation or IR is then forwarded to the supplier directly or the buyer for transmittal to the supplier. The supplier’s quality system is then responsible to address the issue and does not require a written response.

5.1.6.3 A subsequent reoccurrence of the non-conformance may result in a CAR being initiated. This subsequent action is at the discretion of the CAA, QA Eng., HoQ or CAB.

5.2 Certified AS9100/ISO 9001 Certified Suppliers 5.2.1 For AS9100/ ISO 9001certified suppliers, the issuance of a NOTIFY

VCAR does not require a written response. This notification of a defect requires action on their part per the AS/ISO standard; therefore, a formal reply back to B-E is not required.

5.2.1.1 The NOTIFY VCAR being issued in these circumstances is to have the statement in the Immediate Corrective Action Block: “This notification is being provided to you for corrective/ preventive actions within your systems under the applicable AS9100/ ISO 9001 requirements. A reply back to B-E is not required; action on your part is required per the applicable standard as part of your certification.”

5.2.1.2 The VCAR is considered closed at B-E upon the formal notification to the supplier of the discrepancy.

5.2.1.3 VCAR(s) issued prior to this revision meeting the requirements outlined above, will be considered closed as notification of the discrepant condition has been provided to the supplier.

5.2.2 An alternate means of supplier notification may include an Inspection Report (Form BF-1064), to include “This notification is being provided to you for corrective / preventive actions within your systems under the applicable AS9100/ ISO 9001 requirements. A reply back to B-E is not required; action on your part is required per the applicable standard as part of your certification.” Form QC-1421 may be used alternatively.

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Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

5.2.3 A standard VCAR (using Form QC-1338) may be assigned to AS9100/ ISO 9001 suppliers as circumstances dictate, at the discretion of B-E Quality Engineering, Supplier Quality, Purchasing, CAT or CAB members.

5.3 Preventive Action (Enhancement Opportunities):

5.3.1 Preventive Action or Enhancement Opportunity is provided for as applicable under the CAR form block titled “Corrective/Preventive Action (Required for both Corrective and Preventive Actions):.These actions are not to correct a non-conformance, but to limit the potential for non-conformities with appropriate preventive actions.

5.3.2 Preventive Action opportunities identified may be included in the CAR Log. These opportunities, when included, will be identified with a code “EO” (Enhancement Opportunity) and handled per this procedure.

5.3.3 The corrective/preventive action data provided to the CAB by the HoQ or CAA is a potential source to review for additional preventable action opportunities.

5.3.4 Work teams addressing the prevention of non-conformance(s) within any process may initiate PAs (EOs) as a result of investigations. These teams may initiate a CAR, or solve the problem directly.

5.4 Completion Process 5.4.1 Requests for due date extension(s) may be authorized by the CAA and are

indicated by the changed date in the CAR Log and the inclusion of “YES” in the EXTEND column. The CAR form should also be updated to reflect the revised due date.

5.4.2 Complete the CAR Form

5.4.2.1 CAR(s) are Quality Records and are to be maintained per OP 16.1.

5.4.2.2 Provide objective evidence of Containment, Corrective and Preventive Action(s) (as applicable) taken; i.e., stock purges, shipping holds, routing changes, procedure changes, training records, completion dates, copy of implementation documentation or plan, name of person responsible for

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Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

implementation of CA, etc., where deemed appropriate by the CAA.

5.4.2.3 Provide objective evidence to support the steps necessary to determine the root cause for complex issues or when determined as necessary by the CAA.

5.4.3 The responsible process owner or supplier also completes the Validation of Effectiveness of the Corrective Action. The process owner or supplier is responsible to identify the actions taken or to be taken to verify that the corrective actions are effective. The objective evidence of the verification is required to be provided to Breeze-Eastern when completed. If the verification is not complete when submitting the CAR response, the date and the person responsible to accomplish the verification is required.

5.5 CA/PA Review Process 5.5.1 The CAA is authorized to close CAR(s). The CAA reviews all CA/PA(s)

for completeness and determines appropriate follow up activity, if necessary.

5.5.2 The CAA approves the response based on the acceptability of the CA/PA Plan or the completed CA/PA response.

5.5.3 For CAR responses where there are pending action items, these are identified with a due date in the Pending Action Item Due and added to the CAR Log PEND ACTIONS column. The Due Date in the CAR Log is changed to match the PEND ACTIONS date. If there are no pending action items, this block may remain blank or have a response identifying completed pending action items. The hardcopy of the CAR can be updated by drawing a single line through the dates, adding the revised date, initialing, and dating the form. The hardcopy of the CAR Form is the Quality Record.

5.5.4 When the CAR response is complete, including all outstanding pending action items, the CAA signs and date the Closed Date block. This approval constitutes the acceptance of the CA/PA and its associated objective evidence for all CA/PA responses. Responses with completed Verification of Effectiveness actions are signed and dated in the

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Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

Effectiveness Review Date block. This is the final completion of the CAR.

5.5.5 For CAR responses with outstanding Verification of Effectiveness actions, the due date for completion of this action is entered in the Effectiveness Review column in the CAR Log and on the CAR Form. Upon receipt of the Verification of Effectiveness action closure, the Effectiveness Review Date block on the CAR form is signed and dated by the CAA; indicating final completion of the CAR.

5.5.6 The date of closure is entered into the DATE CLOSED column of the CAR Log.

5.5.7 The CAB has the final authority on the resolution of questioned CAR(s) determined unacceptable by the CAA.

5.5.8 The CAA forwards CAR(s) subject to customer review to the customer or through others, as appropriate. CAR (s) subject to government review get forwarded by the CAA or CAB to the resident government office directly.

5.5.9 CAR(s) not accepted by the customer are to be coordinated by the CAA with the CAT and CAB for further resolution.

5.5.10 The CAA reviews the CAR Log and CA status for trends at least annually and submits any identified trends to the HoQ for the CAB.

5.5.11 The CAA reviews the CAR Log to verify that responses are received before assigned deadlines. The initial response time is set by the CAA, normally 20 calendar days or as specified by the CAA or the customer.

5.5.12 Extensions of due dates are consistent with the complexity of the analysis of the corrective action implementation and the criticality of the problem.

5.5.13 When responses become due, it is the CAT responsibility to provide resolution or contact the CAA requesting a revised response date. The CAA will attempt to negotiate an acceptable revised response date.

5.5.13.1 In the event that the CAA, CAT and/or customer cannot agree on an acceptable date, the CAB is responsible for a final resolution.

5.6 Environmental Actions

OPERATING PROCEDURE OP 14.1

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Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

5.6.1 Corrective and preventive actions for findings or opportunities within the requirements of the EMS are identified, evaluated, investigated and initiated in accordance with the requirements of this procedure.

5.6.2 In addition to the requirements of this procedure, corrective actions for the EMS get initiated when the following occurrences are discovered:

5.6.2.1 Any significant spill (i.e. five (5) gallons or more) occurs.

5.6.2.2 A fire or explosion.

5.6.2.3 Any environmental event requiring notification to any regulatory agency/authority.

5.6.2.4 Any other process or other nonconformities noted by QA, an EMSSC member, or as allowed by this procedure.

5.6.3 Any actions taken are appropriate to the magnitude of the problem or potential problem(s) and the environmental impacts encountered.

5.6.3.1 Actions are designed to prevent or mitigate the environmental impacts of the actual or potential problem.

5.6.3.2 Changes required to EMS documentation as a result of actions are affected to preclude or prevent occurrence/ recurrence of the finding or opportunity.

5.7 Records, Audits, & Training

5.7.1 The records of Corrective and Preventive Actions are to be retained in accordance with the requirements of OP 16.1 Control of Records.

5.7.2 The Corrective and Preventive Action process is subject to audit per OP 17.1 Compliance Evaluation Audits.

5.7.3 Training is provided for those persons involved in the Corrective and Preventive Action process per the requirements of OP 18.1 Training Program.

OPERATING PROCEDURE OP 14.1

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6.0 REVISION HISTORY:

REV DATE OWNER DESCRIPTION OF CHANGE(S)

A 11/14/97 Initial Registration Audit

B 04/02/98 Added para 4.2.3 & para 7.3. Corrected numbering of 7.1, 7.2, and 7.3 under para 8.0 to 8.1, 8.2, and 8.3.

C 07/09/99 New para 7.3 created. Renumbered old para 7.3 to 7.4 D 03/08/04 Para 4.4.4 and 4.1.5, added 2nd sentences. Para 4.2.1 and

4.2.3, added last sentences. Para 5.0, re-titled and rewritten to include a log and a new para 5.2.

E 09/23/04 Complete re-write - Rev Bars not used. F 04/11/06 Added para. 6.6 for ISO 14001 requirements G 9/23/08 Norm Harris Incorporate DCN 08-01Q, deleted reference to Q 14.001 & Q

14.002 Procedures, reformat, no revision bars used. Update 5.5.1 to clarify “Follow-up” requirements (PJR CAR AS2008-05078 GN-05, B-E ICAR 1221). Clarified 5.1.2 requirement for consultants to initiate a CAR for findings when performed for the Company. Added definition of “non-conformance costs”. Corrected process flow chart, added reference to chart. Eliminated repeat full name callouts where abbreviations have been defined. Added definitions to CAR instructions.

H 4/3/12 Norm Harris Reformatted section 2, added new B-E logo, added definition for CA/PA form, VCAR & EMS, replaced VPQ with HoQ (Quality Dept. Head), 5.5.3 changed CAT to CAA, updated Appendix 3 with current CAR form and updated the Instructions for completing a CAR form, Reformatted section 5 procedure. Changed CAL to CAR Log. Added several procedural updated as identified by the rev. bars. Minor grammatical changes are not identified by rev. bars. Examples 1 – 6 in Appendix 2 were removed.

J 1/8/13 Norm Harris 2.2 & 2.3 removed unnecessary verbiage. Added separate sections for procedures, forms and definitions. Added OP 21.1, moved all definitions under 3.3, expanded definitions for clarification, rewrote 4.0 to consolidate the responsibilities. Added OP 21.1 to 5.1.1.1. Updated 5.1.3 to change Any CAT to If a CAT to clarify action. Added verbiage to clarify closing a “NOTIFY” CAR. 5.2.5 Removed reference to

OPERATING PROCEDURE OP 14.1

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CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

Preventive action. 5.3 Re-arranged Preventive Action (Enhancement Opportunities as a separate section after Corrective Actions to eliminate confusion. 5.3.3 Clarified to change the due date to match the Pending Action date. 5.5.15 Added verbiage defining actions when completing the Effectiveness review. Changed title of Appendix 2 to eliminate reference to Preventive Actions.

K 11/15/13 Norman Harris Update and reorganize format to current rev. 2.0. Add ‘Warranty returns will be addressed separately and at the discretion of the Quality Representative performing the review and analysis. A CAR may be generated as a result of this effort.’ 3.3.2 Added QC-1398, Final Inspection Hold. 4.1.1 Add ‘14 CFR Part 21, Certification Procedures for Product and Parts.’ 4.2.7 Eliminated redundant requirements (4.7.16, 4.7.17, 4.7.18). 4.2.7.2 Added ‘determined to be a significant impact to the Company’s ability to meet its commitments’. 4.2.7.3 Added ‘for those non-conformances determined to have a significant impact in the ability to meet its commitments.’ 4.2.7.6 Added ‘based on the significance of the non-conformance and its impact on the Company.’ Added 4.2.7.10 ‘Review the status of aged CA(s) to determine their significance or benefit to continue resources and efforts to resolve, refocus resources to resolve them, or to close them.’ 5.1.2 Changed ‘outside consultants’ to ‘contract consultants’. 5.1.2.3 Added ‘CUS’, changed department to ‘department or customer name’, added QN#, SCAR#, PQDR#. 5.1.3 Added ‘format’ to end of sentence. 5.1.2.6 Added QN, QPDR and ‘and the supplier where the email address is known by the CAA’ to the end of the sentence. 5.1.5 Added ‘An example of this situation is the QC Form -1398, Final Inspection Hold, utilized in Q10.003 for Final Inspection.’ To the end of the paragraph. 5.1.7.7 Changed ‘and requested’ to ‘a request to’ and added ‘may be made’ to the end of the sentence. 5.2.2 Added ‘or in stock’. 5.2.4.3 NOTE: Added ‘or contributing cause’ after symptom. 5.2.5 Added ‘This action requires that the process, procedure, technical documentation, special process, router, etc. changes in order to affect the cause.’ 5.2.6 Changed ‘If yes’ to ’If no’ for actions. 5.3.6 Added ‘If no, repeat the process.’ after the first bullet. Updated the QC-1338 form to the current revision in Appendix 3.

OPERATING PROCEDURE OP 14.1

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QUALITY

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Issue Date

06/21/16

Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

L 3/3/15 Norm Harris Update paragraph 5.5.15 to add/clarify Effectiveness requirements. The changes are identified by the underlines. 5.5.15 The CAA may assign an Effectiveness Review Date as deemed appropriate based on the nature and severity of the non-conformance, up to one (1) year after implementation of the CA, to determine if the CA was effective. Other Effectiveness Review Dates may be assigned by the CAA or as directed by the HoQ. Suppliers/ CAR Owners and/or the CAA are to identify the validation efforts/actions taken to validate the effectiveness of the CA (space provided on the QC form 1338 – Validation of Effectiveness of the Corrective Action. The Effectiveness Review may also consist of the evaluation of the CAR Log to determine if subsequent CARs were initiated since the closure of the initial CAR or as determined by the CAA. At the completion of the review, the Effectiveness Review Date shall be deleted from the CAR Log and a note added to the comments column indicating that the review occurred and the date. It is required that the review be noted on the hardcopy of the CAR.

M 5/5/15 Norm Harris Removed reference to OP 13.1. Added 3.3.1 AS definition. 3.3.5 Updated definition for CA/PA. 3.3.6 Added “Containment or” to definition. Changed Appendix from 3 to 2. 3.3.20 Added “potential” to the definition. 3.3.21 Added “Definitive” to the Root Cause definition. Deleted 4.2.3 and included in 4.2.1. 4.2.7.2 Changed “determined” to “deemed”. 4.2.7.9 Added “the containment” after “Determining”. 5.1.2.3 Added bullet “The originator of the CAR,” Changed definitions for P/N Nomenclature to Part Number, Nomenclature, P.O. Number and Quantity”, ISO/AS Element to “Requirement Document” and “Finding/Deficiency/Observation” to “Non-conformance to the requirement”. Removed last sentence in the following Note: 5.1.4 changed “initiate” to “request the initiation of “Deleted 5.1.7. Deleted 5.2 and moved 5.7 to 5.2. Removed 5.3.5 & 5.3.6. 5.4.4 Rewritten to include the updated approach to the “Verification of the Effectiveness of the Corrective Action”. 5.5.4 Added “Responses with completed Verification of Effectiveness actions shall be signed and dated in the Effectiveness Review Date block. This is the final completion of the CAR.” 5.5.5 Rewritten to address the

OPERATING PROCEDURE OP 14.1

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QUALITY

Controlling Department

09/02/97

Issue Date

06/21/16

Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

“Validation of Effectiveness changes”. 5.5.15 Removed to address “Validation of Effectiveness changes”. Deleted Appendix 2 and Replaced Appendix 3 and Revised QC-1338 Form. These changes made in response to CAR 3286.

N 9/16/15 Alan Moss DCN 15-15QA- Sect. 3.0 “References & Definitions”, para. 3.1.5 Corrected title of referenced Work Instruction Q10.003 from “Final Inspection Procedure” to “Final Inspection Work Instruction”.

P 04/11/16 Fred Willms DCN 16-05QA Added 3.2.3 and 5.2.2 to ref. Form BF-1064, changes to sections 4.2.6.13 changing CAB Mtg. interval from twice to once annually; 5.5.10 CAR metrics formal reporting analysis changed from monthly to annually; sec. 5.2 updated notification options to either Form BF-1064 or QC-1338 for AS9100/ ISO9001 suppliers.

R 06/21/16 Lars Novak Incorporated DCN 15-15 and DCN 16-05 changes. Added sec. 3.3.23 “Containment Action”; changes to Sec. 5.4 Completion Process and changes to sec. 5.1.1 & 5.1.2 in response to CAR 3454 to increase awareness and understanding regarding Containment Action. Rev. bars used. Renumbered 5.7-5.9 into 5.7. Removed definitions not being used within document (e.g. CAP); removed “shall” in section 5 (No rev bars used). Added 3.2.4 and reference to QC Form 1421 in 5.2.2.

OPERATING PROCEDURE OP 14.1

Revision: R Page 19 of 20

QUALITY

Controlling Department

09/02/97

Issue Date

06/21/16

Revision Date

CORRECTIVE AND PREVENTIVE ACTION Notes: AS9100C Compliant

Breeze-Eastern Form QC–1298, Rev P, February 26, 2016 Uncontrolled Document when printed – Revision must be confirmed per OP 2.1 ©2016 Breeze-Eastern LLC. All Rights Reserved. Contents Proprietary Information of Breeze-Eastern LLC

Appendix 1 – Process Flowchart

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